On March 21, 2016, the Plaintiff and the Company
entered into a settlement agreement whereby the Company agreed to settle for a cash payment of $250,000 due December 16, 2016.
On March 8, 2017, the settlement agreement was amended with an initial payment of $190,000 to be delivered by March 15, 2017 and
the remaining balance of $60,000 shall be paid in twelve (12) monthly payments of $5,000 each through April 1, 2018. At March 21,
2016, the Company reclassified $195,845 accounts payable and $54,155 notes payable, related party to settlement payable in the
accompanying balance sheet. As of December 31, 2018 and 2017, the outstanding balance due was $0 and $15,000, respectively.

On March 7, 2016, Jeffery D. Segal, A Professional
Corporation (“Segal”) filed a complaint against the Company alleging failure to pay for legal services rendered in
aggregate of $59,174 with the Superior Court of the State of California, County of Los Angeles.

In March 2017, the Company entered into a settlement
agreement to pay the plaintiff and did pay $65,000 in full settlement. The Company has accrued the $65,000 for the year ended December
31, 2016.